2025 Petition - Macomb - Cho Condos.pdf
Cmg Romeo Plank LLC, Petitioner Vs. Township Of Macomb, Respondent · 25-001641-TT
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Page 1
STATE OF MICHIGAN
MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM
MICHIGAN TAX TRIBUNAL
CMG ROMEO PLANK LLC,
Petitioner,
vs.
MACOMB TOWNSHIP,
Respondent.
/
MTT Docket #25-
Parcel No. Various
PETITION
CMG ROMEO PLANK LLC (“Petitioner”), through its attorneys, Law Office
of Aaron M. Fales, P.C., says:
1.
Petitioner's principal office address is 43900 Garfield Rd., Ste. 203,
Clinton Twp., MI 48038. Petitioner is a party in interest with respect to property
taxes on contiguous (Office condos in the same building) real property tax
parcel nos. as identified in section 3 hereof ("Petitioner's Property"), at 46591
Romeo Plank, Macomb, MI.
2.
Respondent, Macomb Township assesses and collects property
taxes on Petitioner's Property.
3.
In 2025, Respondent determined the value of Petitioner's Property
to be:
Parcel #
Address
2025 AV/SEV
2025 TV
08-32-230-001
46591 ROMEO PLANK RD
$330,200
$244,390
08-32-230-003
46591 ROMEO PLANK RD
$352,200
$260,664
08-32-230-004
46591 ROMEO PLANK RD
$679,100
$502,634
08-32-230-007
46591 ROMEO PLANK RD
$361,300
$267,385Page 2
08-32-230-008 46591 ROMEO PLANK RD $61,200 $45,279 08-32-230-009 46591 ROMEO PLANK RD $106,800 $78,980 08-32-230-010 46591 ROMEO PLANK RD $641,100 $474,499 08-32-230-011 46591 ROMEO PLANK RD $618,300 $457,641 08-32-230-013 46591 ROMEO PLANK RD $424,000 $372,343 08-32-230-015 46591 ROMEO PLANK RD $191,800 $183,804 4. Petitioner's Property is classified as Commercial Real Property. Petitioner's Property is an office Building. Petitioner believes that Petitioner's Property was originally designed to be used for commercial purposes. 5. This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable value, and (d) uniformity. 6. At this time, Petitioner believes, as it relates to taxable value, that there is a dispute relative to the value of a loss. 7. The 2025 assessments, including state equalized value and taxable value, imposed on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful and operate as a fraud upon the taxpayer for the reasons that: (a) The assessment, including state equalized value and/or taxable value, exceeds the amount permitted by the Michigan Constitution and applicable statutes; (b) The assessment, including state equalized value and/or taxable value, are at higher percentages of true cash value than permissible under the Michigan Constitution and applicable statutes;
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(c) The assessment, including taxable value and/or state equalized value, are based upon an erroneous determination of the true cash value of that portion of Petitioner's Property that is taxable under Michigan law, and are based upon the application of wrong principles; and, (d) The assessment, including state equalized value and/or taxable value, and the mode of assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its constitutional rights to uniformity, equal protection and due process of law. WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order reducing the 2025 to be the following: Parcel # Address 2025 AV/SEV 2025 TV 08-32-230-001 46591 ROMEO PLANK RD $100,000 $100,000 08-32-230-003 46591 ROMEO PLANK RD $100,000 $100,000 08-32-230-004 46591 ROMEO PLANK RD $200,000 $200,000 08-32-230-007 46591 ROMEO PLANK RD $100,000 $100,000 08-32-230-008 46591 ROMEO PLANK RD $25,000 $25,000 08-32-230-009 46591 ROMEO PLANK RD $25,000 $25,000 08-32-230-010 46591 ROMEO PLANK RD $200,000 $200,000 08-32-230-011 46591 ROMEO PLANK RD $200,000 $200,000 08-32-230-013 46591 ROMEO PLANK RD $100,000 $100,000 08-32-230-015 46591 ROMEO PLANK RD $100,000 $100,000 and requiring Respondent to pay Petitioner the refunds attributable to such reductions, plus interest and costs.
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Dated: May 29, 2025 Respectfully submitted, LAW OFFICE OF AARON M. FALES, P.C. Attorney for Petitioner By: _________________________ Aaron M. Fales (P72864) 330 Hamilton Row, Ste. 350 Birmingham, MI 48009 (248) 767-9840